The author previously published a paper discussing how to conduct an analysis based on a cluster sample. In that paper, the author outlined several widely adopted alternative approaches, and pointed out that such approaches are anyway not needed for population figures, and not possible for non-probability samples. Thus, the author queried the prevalence and relevance of complex approaches such as multi-level modelling (MLM) for most real-life analyses. Hutchison and Schagen (2008) responded with a paper that misrepresents what the author said, in an attempt to defend their favoured technique of MLM. In this article, the author wants to establish their misunderstanding of this important topic. This paper deals first with areas in which they agree, and then areas in which Hutchison and Schagen (2008) simply restate their position, before turning to the more substantive consideration of why it is not necessary or appropriate to use MLM in most real analytical situations. (Contains 2 notes.)